Privacy Policy
Last updated: September 29, 2026
The Anti Drug Ad Campaign (“we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information about you when you use our website (www.antidrugad.com), and any other websites, applications, products, or services that link to this Privacy Policy (together, the “Platform”), or when you otherwise communicate with us. We use the terms “you” and “your” to mean any person who uses our Platform. The Anti Drug Ad Campaign is the controller of your personal data for purposes of the EU and UK General Data Protection Regulations. This Privacy Policy does not apply to information you provide to third parties, including websites or services that are linked from our Platform. If you are a California resident, please see our CCPA Privacy Notice for California Residents in Section 15. If you live in another U.S. state with a consumer privacy law, please see Section 9. If you are in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, Sections 3, 7, and 8 contain additional information that applies to you.
This Privacy Policy applies only to personal information for which we decide why and how it is processed.
Quick links:
- 1. What information do we collect about you?
- 2. How will we use the information about you?
- 3. What is our legal basis for processing your data? (EEA, UK, and Switzerland)
- 4. What will we disclose and share with third parties?
- 5. How do we protect your information?
- 6. How long do we keep your information?
- 7. International Transfers
- 8. Your Rights (EEA, UK, and Switzerland)
- 9. Your U.S. State Privacy Rights
- 10. Cookies, Pixels, and Other Tracking Technologies
- 11. Artificial Intelligence and Automated Tools
- 12. Terms of Use and Dispute Resolution
- 13. Changes to our Privacy Policy
- 14. How to contact us
- 15. CCPA Privacy Notice for California Residents
1. What information do we collect about you?
Information you give to us
Some of our products and services require certain information, and we may not be able to provide them if you choose not to provide it. We will tell you at the point of collection which information is required and which is optional. The information you give us may include: your name, postal address, email address, telephone number, date of birth, account login credentials, and any other information you choose to provide, such as when you fill out a web form, post a review or comment, enter a sweepstakes or contest, respond to a survey, or apply for a job. This may include your interests, preferences, feedback, and survey responses.
Information we collect automatically when you use our sites or services
We may collect information about your interaction with our sites and services from the devices you use, such as your unique device ID, device type and advertising ID. We may also collect information about your visits and activity on our Platform including the content and any advertisements that you view and interact with, the address of the site from which you arrived and other technical data about your equipment, browsing actions and patterns (such as the pages you view, the links you click, the items you add to your shopping basket, the length of your internet session, your IP address and approximate location at the time of browsing). This information is collected using cookies, pixels, software development kits (SDKs), server-to-server integrations, and similar technologies, including session replay tools that record how you interact with our pages. See Section 10 (Cookies, Pixels, and Other Tracking Technologies) for more information.
Information collected from other sources
We may combine your information with information we collect from third parties or public sources, including analytics providers, advertising networks, social media platforms, data brokers, our business and co-marketing partners, and publicly available sources. We also obtain information about you where you have given a third party permission to share it with us or as otherwise permitted by applicable law.
Sensitive information
We do not intentionally collect sensitive personal information, such as precise geolocation, health information, government ID numbers, or information about racial or ethnic origin, religious beliefs, or sexual orientation.
Children’s data
Our Platform is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it. If you believe we may have collected information from a child under 13, please contact us using the details in Section 14. We do not knowingly sell or share the personal information of consumers under 16, or use it for targeted advertising.
2. How will we use the information about you?
We may use your information for the following purposes:
- Customer Relationship Management: to contact you about your account, subscription or other order; to provide you with customer service (such as responding to questions, concerns and feedback and contacting you via email, telephone, SMS/text, post, direct message or other similar communication method for this purpose); to notify you of material changes to our terms or this Privacy Policy; to send you service related communications; to ask you to leave a review or take a survey.
- Sweepstakes, Contests, Events, Product Trials, Surveys, Awards: to enable you to participate in sweepstakes, contests, product trials, events, awards, surveys, polls and quizzes and to provide you with any prizes, products or awards as applicable.
- Business Administration, Systems and Security: to administer and protect our business and our sites such as troubleshooting, testing, system maintenance, support, reporting and hosting data; to ensure network and system security and prevent, detect, mitigate and investigate fraud, security breaches and other prohibited or illegal activities; to verify your identity.
- Data Analytics: to measure the performance of our marketing campaigns (for example, analyzing open and click rates); to provide insight and analysis of our customers for ourselves and our business partners.
- Marketing: to provide you with marketing via email, post, telephone, SMS/text, social media and other digital channels (including Meta Custom Audiences and Google Customer Match); to make suggestions and recommendations to you about goods and services that could be of interest to you. See Marketing below for more information.
- Advertising: to select and deliver advertising and content to you and measure the delivery and effectiveness of such advertising and content.
- Personalization: to personalize content, services and communications and target advertising, as further explained in Personalization and Advertising section below.
- Aggregation and De-identification: to aggregate and de-identify your data, which we maintain in de-identified form and do not attempt to re-identify, so that we can sell advertising and monitor the effectiveness of our business partnerships.
- Artificial Intelligence: to personalize content, and detect fraud using artificial intelligence and machine learning tools, as described in Section 11.
- Legal Compliance: to comply with our legal obligations, respond to lawful requests from authorities, enforce our Terms of Use, and honor your privacy choices and rights.
Personalization and Advertising
We want the ads and content displayed on our Platform to be relevant to you. Personalizing and targeting advertising, content, services and communications allows us to provide you with much of our sought-after online content for free.
We will use your information to provide you with personalized content, services and communications as well as targeted advertising on our Platform, sites operated by our group companies and selected partner sites. Where permitted by law and, where required, with your consent, we do this by matching, combining or linking the different sources of information we hold about you (e.g., linking your contact or subscriber information with your activity across our Platform or by linking your activity on our Platform across all your devices using your email or social media log-in details) or by creating segments based on various factors such as your age and gender, your device details or your inferred interests. This may include providing a hashed (encoded) version of your email address or phone number to advertising platforms such as Meta and Google so they can match it with their users. We work with data management platform providers to assist with this process.
We also use your information for retargeting (for example, you could see an advertisement on a partner site such as Facebook or Instagram for a product that you have recently viewed on our sites). These activities involve the use of cookies, pixels, and similar technologies (see Section 10). Under the privacy laws of California and certain other U.S. states, some of these activities may be considered a “sale” or “sharing” of personal information or “targeted advertising.” You can opt out as described in Sections 9, 10, and 15. If you are in the EEA, the UK, or Switzerland, we use non-essential cookies and similar technologies for these purposes only with your consent.
Marketing
Where we have the appropriate permissions or as otherwise authorized by applicable law, we will use your information to market and advertise our products and services and occasionally third-party products and services that could be of interest to you including third party offers, advertisements, competitions or commercial communications by telephone (mobile and landline when available), post, electronic messaging (including SMS and MMS), email, online or via applications. Our third-party service providers may send these communications on our behalf. We will send you marketing text messages (SMS/MMS) only if you have given your prior express written consent, and consent is not a condition of any purchase. Message and data rates may apply. You can opt out of text messages at any time by replying STOP.
You can always tell us that you wish to stop receiving direct marketing communications from us.
If you would prefer not to receive direct marketing communications, simply let us know at any time by writing to [email protected], or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving service messages from us.
3. What is our legal basis for processing your data? (EEA, UK, and Switzerland)
Where the EU General Data Protection Regulation (“GDPR”) or UK GDPR applies, we rely on the legal bases described below for the applicable processing purposes. Where Swiss data protection law applies, we comply with that law and rely on consent, an overriding private or public interest, or a legal provision where justification is required.
Fulfilling a contract with you, or taking steps at your request before entering into a contract, including to: register you as a customer or create an account needed for our products and services; process and deliver your order; manage payments, fees, and charges; provide the products, services, or customer support you request; send necessary account, order, and service communications; and administer a promotion or event you enter where this is necessary to perform our agreement with you.
Complying with a legal obligation under applicable EEA or UK law, including to: maintain legally required records; respond to legally binding requests from authorities; and comply with applicable privacy and consumer-protection requirements.
Our legitimate interests (or those of a third party), where those interests are not overridden by your interests or fundamental rights and freedoms, including to: measure the performance of our marketing campaigns without consent-dependent tracking; provide you with marketing by post; provide you with marketing by email about similar products or services where permitted by applicable marketing law and you have purchased goods or services from us (you can opt out at any time); ask you to leave a review or take a survey; administer and protect our business and our sites, such as troubleshooting, testing, system maintenance, support, reporting, and hosting data; use data analytics that do not require consent to understand how customers use our Platform; and aggregate and de-identify data. The legitimate interests we rely on for this processing are: to keep our records updated; to study how customers use our products and services; to improve the customer experience; to develop our products and services; to develop and grow our business; to provide administration and IT services; for network security and fraud prevention; in the context of a business reorganization or group restructuring; and to inform our marketing and content strategy. You can ask us for more information about how we balanced these interests. We do not rely on legitimate interests to override a refusal or withdrawal of consent for processing that requires consent.
Your consent, including to: place non-essential cookies, pixels, and similar technologies on your device and use the information they collect for analytics, personalization, targeted advertising, and retargeting (see Section 10); share your information with advertising partners, including through Meta Custom Audiences and Google Customer Match; make personalized suggestions and recommendations to you about goods and services that may interest you; provide you with marketing by email (where you are not an existing customer), SMS/text, and telephone, including from our third-party service providers; and share insights about our customers with our business partners. You can withdraw your consent at any time through the “Privacy Settings” link in our website footer, by following the unsubscribe instructions in our communications, or by contacting us. Withdrawing consent does not affect processing that took place before you withdrew it.
4. What will we disclose and share with third parties?
We share your personal data with our third-party service providers for the purposes outlined in this Privacy Policy, such as to enable them to process a request, order or service; to supply you with a prize in the event you win a competition; or in order to obtain information. We may use a number of IT service providers inside and outside the European Union to store data and customer management information, provide disaster recovery services, and related IT services that we need to conduct our business and perform any contract we enter into with you. Any third parties we contract with to process your data on our behalf are required by contract to process it only on our instructions and to protect it using appropriate security measures.
Depending on how you use our Platform, the categories of third parties with whom we share personal information include: service providers and processors (such as hosting, IT, email and SMS delivery, and analytics providers); advertising and marketing partners (such as advertising networks, social media platforms, and data management platforms); professional advisors (such as lawyers, accountants, and auditors); and government authorities and law enforcement, where required by law.
We do not permit our service providers and processors to use your personal information to market their own products or services to you.
We share information with advertisers, ad servers, ad networks, social media platforms, and content recommendation services to select and deliver advertising and content, and to target and personalize advertising and content both on our sites and on partner sites. The information we share may include cookie and device identifiers, IP address, browsing and purchase activity, and, where permitted by law, a hashed (encoded) version of your email address or phone number. By interacting with or viewing an advertisement or content, you should be aware that the third party may assume that you meet the targeting criteria used to display it. We also share information with analytics and search engine providers to help us improve and optimize our sites. Depending on where you live, this sharing may be a “sale,” “sharing,” or “targeted advertising” under applicable law, and you may have the right to opt out (see Sections 9 and 15).
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets, we may disclose or transfer your information to the other parties involved, including during due diligence. We will notify you as required by applicable law.
We reserve the right to disclose your personal data in order to comply with the law, applicable regulations and government requests. We may also disclose your personal data where we believe it is necessary to enforce our Terms of Use or to protect the rights, property, or safety of us, our systems, our users, or others.
5. How do we protect your information?
We use reasonable administrative, technical, and physical safeguards designed to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no method of transmitting information over the internet or storing it electronically is completely secure, and we cannot guarantee the security of your information. Please protect any password you use for our Platform, do not share it with anyone, and log out when you use a shared or public device. If we learn of a security incident that affects your personal information, we will notify you as required by applicable law.
Other websites
Please note that clicking on links and advertisements on our sites could result in you being transferred to another website, where data privacy practices vary from ours. If transferred to another website you should consult their privacy policy as we are not responsible for, and have no control over, information that is submitted to or collected by these third parties.
6. How long do we keep your information?
We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
Our data retention periods vary depending on the context of the services that we provide to you and our legal obligations. To determine the appropriate period for which we keep your data, we consider the amount, nature and sensitivity of your data, the potential risk or harm from unauthorized use or disclosure of your personal data, the purposes for which we process that data (and whether we can achieve those purposes through other means), and applicable legal requirements.
The retention period for each category of personal information we collect is described in the table in Section 15.
7. International Transfers of Data and Information
We are based in the United States, and our Platform is hosted in the United States. If you are located outside the United States, your personal information will be transferred to, stored, and processed in the United States, and any other country designated within the privacy policy of a third party to which we have been given a right of disclosure as further detailed within this policy. These countries may have data protection laws that differ from those in your country.
8. Your Rights (EEA, UK, and Switzerland)
If you are located in the EEA, the UK, or Switzerland, you have certain rights in relation to the personal data we hold about you, which we detail below. Certain rights only apply in specific circumstances as set out in more detail below. We have also described how you may exercise those rights. When you exercise your rights, we need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will also contact you to ask you for further information in relation to your request to speed up our response.
You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legitimate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we could have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we are not always able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data based on our legitimate interests (or those of a third party) on grounds relating to your particular situation. We will stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary to establish, exercise, or defend legal claims. Separately, you may object at any time to processing for direct marketing, including related profiling. If you do so, we will stop processing your personal data for those direct-marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
- Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects concerning you. We do not make such decisions.
If you wish to exercise any of these rights, please contact us using the details in Section 14. We will respond within one month of receiving your request, which we may extend by up to two additional months where necessary. You also have the right to lodge a complaint with the data protection authority in the country where you live or work or where you believe an infringement occurred. Our data protection officer can be reached at [email protected].
9. Your U.S. State Privacy Rights
Residents of certain U.S. states, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, have rights regarding their personal information under their state’s privacy law. California residents should also see Section 15. Depending on where you live, and subject to certain exceptions, you may have the right to:
- Confirm whether we process your personal information and access it.
- Correct inaccuracies in your personal information.
- Delete your personal information.
- Obtain a copy of your personal information in a portable and, to the extent feasible, readily usable format.
- Opt out of the sale of your personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Obtain a list of the specific third parties, or categories of third parties, to which we have disclosed your personal information, where your state’s law provides this right.
- Where required by your state’s law, give or withdraw consent before we process your sensitive personal information.
How to exercise your rights
You can submit a request by emailing us at [email protected]. You can opt out of targeted advertising and sales by clicking the “Privacy Settings” link in the footer of our website or by enabling a recognized opt-out preference signal, such as Global Privacy Control, in your browser. We will verify your identity before responding to a request to access, correct, or delete personal information. Where your state’s law permits, you may use an authorized agent to submit a request on your behalf. We will respond within the time required by applicable law.
Appeals
If we decline to take action on your request, you may appeal our decision by emailing us at [email protected] with the subject line “Privacy Request Appeal” within a reasonable time after you receive our response. We will respond to your appeal within the time required by law and explain the reasons for our decision. If you are not satisfied with the outcome of your appeal, you may contact the attorney general of your state.
Sensitive data
We do not sell sensitive personal data.
Nondiscrimination
We will not discriminate against you for exercising any of these rights.
10. Cookies, Pixels, and Other Tracking Technologies
We and our third-party partners use cookies, pixels (also called web beacons or clear GIFs), tags, software development kits (SDKs), JavaScript, local storage, log files, server-to-server integrations (such as conversion APIs), and similar technologies to collect information about your browsing activities on our Platform and, in some cases, across other websites and online services over time. A cookie is a small data file stored on your computer or mobile device by your web browser. We use these technologies in the following categories:
- Strictly necessary: required for our Platform to function, such as keeping you logged in, remembering items in your cart, keeping the Platform secure, and remembering your privacy choices. These cannot be turned off.
- Functional: remember your preferences and settings and enable features.
- Analytics and performance: help us understand how visitors use our Platform, such as which pages are visited and for how long. Our analytics providers include Google Analytics.
- Advertising and targeting: allow us and our advertising partners, such as Meta and Google, to deliver ads that are more relevant to you, measure ad performance, and show you our ads on other websites and apps.
Video. Our Platform includes video content. We do not disclose information that identifies you together with the specific videos you watch to third parties without your consent.
Your choices. When you first visit our Platform, we ask for your consent before activating non-essential cookies and similar technologies. You can accept all optional purposes, reject non-essential technologies, or select individual purposes through Cookie Settings. We do not activate these technologies before your affirmative consent; continuing to browse, scrolling, or closing the banner does not provide consent. You can change or withdraw your preferences at any time through the “Privacy Settings” link in the footer of our website. We honor Global Privacy Control and other recognized opt-out preference signals as a valid request to opt out of the sale or sharing of personal information and targeted advertising for that browser or device, associated consumer profiles, and, where we know who you are, your account and other personal information we can associate with you. We display whether your signal has been honored in Privacy Settings. Cookie preferences do not replace your rights to opt out of sale, sharing, or targeted advertising, including activities that do not use cookies, as described in Sections 9 and 15. You can also block or delete cookies through your browser settings, but some features of our Platform may not work properly if you do. Opting out of targeted advertising does not mean you will stop seeing ads; the ads you see may simply be less relevant to you. A list of the specific cookies, similar technologies, providers, purposes, and durations is available below.
11. Artificial Intelligence and Automated Tools
When you interact with an AI-powered feature, such as our chat assistant, we will tell you that you are interacting with an automated system. We and our AI service providers may use information about your interactions to improve our AI tools. We do not use AI or other automated tools to make decisions that produce legal or similarly significant effects concerning you without meaningful human involvement.
12. Terms of Use and Dispute Resolution
Where you have agreed to our Terms of Use, available at https://antidrugad.com/terms, those terms govern your use of our Platform, including applicable dispute-resolution and governing-law provisions. Nothing in this Privacy Policy or the Terms of Use limits privacy rights or remedies that cannot lawfully be waived.
13. Changes to our Privacy Policy
We review this Privacy Policy at least once every 12 months and update it to reflect changes in our privacy practices. We will post any changes on this page and update the “Last updated” date above. If we make material changes, we will notify you by a prominent notice on our Platform before the changes take effect. If we want to use personal information we have already collected in a way that is materially different from what we told you when we collected it, we will ask for your consent where required by law.
14. How to contact us
If you have any questions about this Privacy Policy or our privacy practices, please contact us by writing to us at:
Email: [email protected]
If you have a disability and need this Privacy Policy in another format, please contact us at [email protected].
15. CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (together, the “CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
This notice also serves as our notice at collection for personal information we collect online. The tables below describe the categories of personal information we collect, the categories of sources from which we collect it, the purposes for which we use it, the categories of third parties to which we disclose it, whether we sell or share it, and how long we keep it. You can opt out of the sale or sharing of your personal information by emailing [email protected].
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected? |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | NO |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | NO |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive personal information. | Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; contents of mail, email, or text messages (unless we are the intended recipient); genetic data; neural data; biometric information processed to identify a consumer; health information; information concerning sex life or sexual orientation; and personal information of consumers we actually know are under 16 years of age. | NO |
For each category of personal information we collect, the table below describes the sources, purposes, disclosures, sales or sharing, and retention period.
| Category | Sources | Business or commercial purposes | Categories of third parties to whom disclosed | Sold or shared? (and to whom) | Retention period |
|---|---|---|---|---|---|
| F. Internet or network activity | Browser Data | Advertising and Analytics | Advertising Networks, Social Networks, Analytics Service Providers | Shared with Google | Indefinitely |
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, when you create an account, place an order, fill out a form, sign up for our emails or text messages, enter a contest, or contact us.
- Automatically from your browser or device. For example, through cookies, pixels, and similar technologies when you visit our Platform or interact with our emails and ads.
- From our service providers and business partners. For example, analytics providers, payment processors.
- From advertising networks, social media platforms, data brokers, and publicly available sources.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you place an order, we will use your information to process your payment and deliver your order.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our campaign, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- To provide personalized content and advertising, including cross-context behavioral advertising, as described in Sections 2 and 10.
- To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.
We will provide any additional notice and obtain any consent required by applicable law before collecting additional categories of personal information or using personal information for materially different, unrelated, or incompatible purposes.
Disclosing, Selling, and Sharing Personal Information
We may disclose your personal information to a service provider or contractor for a business purpose. When we do, we enter into a contract that describes the purpose and requires the recipient to keep that personal information confidential, not to use it for any purpose except performing the contract, and otherwise to comply with the CCPA.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers
- Category F: Internet or other similar network activity
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Sales and sharing. In the preceding twelve (12) months, we have not sold any personal information. We may share personal information for the business or commercial purpose of cross-context behavioral advertising and campaign analytics reporting. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA, and we do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (or, if you ask, for a longer period, covering information collected on or after January 1, 2022, unless providing it is impossible or would involve disproportionate effort). Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, selling, or sharing that personal information.
- The categories of third parties to whom we disclose that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold, shared, or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales or sharing, identifying the personal information categories that each category of recipient obtained through a sale or sharing; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers and contractors to delete, and notify any third parties to whom we sold or shared it to delete, unless this proves impossible or involves disproportionate effort) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is reasonably necessary for us, our service providers, or our contractors to:
- Complete the transaction for which we collected the personal information, fulfill a written warranty or a product recall conducted under federal law, provide a good or service that you requested or reasonably anticipate within our ongoing business relationship, or otherwise perform our contract with you.
- Help ensure security and integrity, to the extent using your personal information is reasonably necessary and proportionate for those purposes.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research that complies with applicable ethics and privacy laws, where deletion is likely to make completion impossible or seriously impair it, and you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
- Comply with a legal obligation.
Correction Rights
You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes for which we process it. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct it.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not use or disclose sensitive personal information for purposes that would give you a right to limit its use under the CCPA.
Exercising Your Rights to Know, Delete, and Correct
To exercise the rights to know (including access and data portability), delete, and correct described above, please submit a verifiable consumer request to us by either:
- Emailing us at: [email protected]
Only you, or someone legally authorized to act on your behalf (an “authorized agent”), may make a verifiable consumer request related to your personal information. If you use an authorized agent, we may require the agent to provide your signed permission and may ask you to verify your identity directly with us, unless the agent has a valid power of attorney. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We will confirm receipt of a request to know, delete, or correct within 10 business days and explain our process and expected response timing, unless we have already granted or denied it. We will respond within 45 calendar days after receipt, including the time needed for verification. If reasonably necessary, we may extend the response period by up to 45 additional calendar days, for a maximum of 90 calendar days from receipt, and will notify you of the reason and extension before the initial period expires. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Unless you ask for information covering a longer period (as described above), any disclosures we provide will cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Right to Opt Out of the Sale or Sharing of Personal Information
You have the right to opt out of the sale or sharing of your personal information at any time. To exercise this right, email us at [email protected]. You can also opt out by enabling a recognized opt-out preference signal, such as Global Privacy Control (“GPC”), in your browser. We process GPC signals as a valid request to opt out for that browser or device and associated consumer profiles and, if we know who you are (for example, because you are logged in to your account), for your account and any other personal information we can associate with you. We display the status of your opt-out in Privacy Settings, including whether an opt-out preference signal has been honored. You do not need to create an account or verify your identity to opt out. After you opt out, we will wait at least 12 months before asking you to opt back in.
We do not use design practices that make it harder to opt out than to opt in, and we will not ask you to reconsider your choice or require unnecessary steps to exercise your rights.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Do Not Track
Some browsers offer a “Do Not Track” setting. Because there is no common industry standard for these signals, we do not currently respond to them. However, we honor Global Privacy Control as described above.
Shine the Light
California Civil Code Section 1798.83 permits California residents to request information about our disclosure of certain personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below.
Changes to Our Privacy Notice
We will review and update this notice at least once every 12 months. When we make changes, we will post the updated notice with a new “Last updated” date.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: [email protected]